Lake Ontario Waterkeeper has filed a formal objection to the application by 3191574 Nova Scotia Company (aka The Highland Companies) for a Class A licence to remove more than 20,000 tonnes of aggregate annually from a pit or quarry in Melancthon Township. Our objection reads as follows:
Craig Laing, Aggregate Inspector
Ministry of Natural Resources, Regional Operations Division
Southern Region, Midhurst District
2284 Nursery Road
Midhurst, ON L0L 1X0
3191574 Nova Scotia Company (The Highland Companies)
477476 Third Line
Rural Route Delivery 2
Shelburne, ON L0N 1S6
April 19, 2011
Dear Mr. Laing and Directors, 3191574 Nova Scotia Company:
EBR No. 011-2864 (Melancthon Quarry)
Objection, Aggregate Resources Act s. 11(3)
Application for Class A licence to remove more than 20,000 tonnes of aggregate annually from a pit or quarry, Aggregate Resources Act s.7(2)(a)
Lake Ontario Waterkeeper objects to the application by 3191574 Nova Scotia Company for a Class A licence to remove more than 20,000 tonnes of aggregate annually from a pit or quarry in Melancthon Township. Waterkeeper makes this objection pursuant to s.11(3) of the Aggregate Resources Act.
Waterkeeper has been an active intervenor in the proposal by Nelson Aggregate to expand that company’s Burlington Quarry since 2005. We are currently participating in the joint Ontario Municipal Board and Environmental Review Tribunal hearing into that proposal.
Nelson’s proposed quarry expansion was the subject of a Joint Agency Review Team [JART] Report, which examined the potential impact of the quarry on the environment, surrounding land use, and social and recreational value in the area. It provided invaluable information on the expected effects on hydrogeology, aquatic life, and ecology, including threatened species discovered on the site by local residents. New information continues to arise in the context of the hearing, indicating the inadequacy of relying solely on proponent-produced and commissioned reports for a project of this type.
The proposed Melancthon Quarry would occupy 937.1 hectares of land just outside of Lake Ontario Waterkeeper’s watershed. The proponent’s application indicates that one billion tonnes has been identified for extraction. Like the proposed Nelson quarry, the aggregate that would be extracted in Melancthon is part of the Amabel Formation, a layer of dolostone that constitutes a valuable aquifer. The bedrock includes karst features, which are formed when groundwater moves through limestone or dolostone bedrock, slowly dissolving the rock and increasing its permeability.
The proposed quarry would reach depths of close to 60 metres or 200 feet, requiring extraction below the water table. The proponent would be required to dewater the quarry to keep it dry for excavation, causing drawdown of surrounding groundwater and potentially impacting local surface water courses. The floor of the existing quarry would continue to be dewatered in perpetuity to allow it to be used for farming post-extraction.
The proposed Melancthon Quarry is many times larger than Nelson’s proposed expansion site. No detailed, site-specific external review of the potential impacts of a quarry of this size and depth has been conducted.
Waterkeeper is concerned about the potential impacts of this project, both during extraction and during the proponent’s proposed post-extraction quarry floor farming operations. The dewatering and pumping that will be required to facilitate the project could have devastating effects on the flow and supply of ground and surface water to lakes, streams, and rivers within and beyond the watershed.
Waterkeeper objects to the approval of this application and respectfully requests that 3191574 Nova Scotia Company’s proposal be denied. In the alternative, Waterkeeper requests that the proposal be referred to a hearing to allow for the examination of scientific evidence by an independent decision-maker and for meaningful public participation.
Thank you for your attention to this matter. Please contact Joanna Bull, Counsel for Lake Ontario Waterkeeper, if you have any questions or concerns about this objection.
President and Waterkeeper